This proposed rulemaking action contains numerous nonsubstantive, editorial,
reformatting of subsections, and grammatical revisions. These nonsubstantive revisions are
not all discussed in this Informative Digest. However, these proposed revisions are
clearly indicated in the regulatory text in underline and strikeout format. In addition to
these nonsubstantive revisions, the following actions are proposed:

Article 5. Window Cleaning

Section 3281. Definitions.

This section contains definitions of terms used in the window cleaning and building
maintenance industries. It is proposed to amend Section 3281 to add a definition for the
term "Competent Person" verbatim of the existing Construction Safety Order
definition contained in Section 1504. The proposed new definition will clarify to the
employer the meaning and intent of the regulations contained in Appendix C to Article 6.
Further revisions are proposed to delete the reference to body belts in the definition of
Personal Fall Arrest System, and add a definition for the term "Terminal Strap
(Runner)". The proposed revision to the definition of personal fall arrest system
will have no effect other than to clarify to the employer that body belts are not to be
used as part of a personal fall arrest system. The term "Terminal Strap
(Runner)" is used to describe the piece of a window cleaners belt that connects
the "waist band" to the "terminal". The term "Runner" was
included as this term is used in ANSI/ASME A39.1-1995, Safety Requirements for Window
Cleaning and by persons in the industry.

Section 3284 provides the requirements for the use of Window Cleaners Belts,
Safety Belts, Harnesses and Other Attachments used for window cleaning operations.

It is proposed to amend the title of this section by replacing the outdated fall
protection terms, "Safety Belts" and "Harnesses", with the current
terminology, "Personal Fall Arrest Systems", "Personal Fall Restraint
Systems" and "Positioning Devices". The effect on the regulated public will
be to make employers aware of the new terminology for personal fall arrest and restraint
systems and positioning devices used for window cleaning and building maintenance
operations.

Subsection 3284(a)(1), General Requirements, requires that safety belts be kept in good
repair, visually inspected prior to each use and inspected by the employer at least twice
a year. A revision is proposed to change the reference from "safety belts" to
"window cleaners belts". The proposed revision will have no effect on the
regulated public, since it merely replaces outdated terminology with that currently used
within the industry.

Subsection 3284(a)(2), Belt Design, requires that window cleaners belts be
labeled as meeting the design and testing requirements of ANSI/ASME A39.1-1991. It also
requires that the label include the name or designation of the manufacturer, model
designation, date manufactured, serial number, and test specifications. Revisions are
proposed to delete the specific labeling requirements, update the referenced ANSI
standard, and require the belts be designed, built and labeled to conform to ANSI/ASME
A39.1-1995. Since ANSI A39.1 already requires the belts to be labeled, the effect on the
regulated public is to eliminate the need for additional and redundant labeling.

Proposed new subsection 3284(c), will require fall protection equipment used in window
cleaning operations to comply with Section 1670 of the Construction Safety Orders. The
effect on the regulated public will be to make fall protection requirements for window
cleaning consistent with fall protection for other industries and to clarify to employers
the requirements for fall protection equipment.

Section 3285. Suspended Scaffolds.

Subsection 3285(c) requires each window cleaner on a working platform to attach their
lanyard to a lifeline that is secured to a fixed anchorage on the roof. Proposed revisions
will require each window cleaner on a working platform to be protected by a personal fall
arrest system that meets the requirements of Article 6, Appendix C, Section I, of the
General Industry Safety Orders. The effect on the regulated public will be to clarify to
employers that fall protection requirements for window cleaners working on suspended
scaffolds are the same as fall protection requirements for employees doing building
maintenance from a suspended scaffold.

Subsection (a)(4) requires that employees using boatswains chairs or CDAs wear
full body harnesses as part of their personal fall arrest system. Proposed revisions will
require these employees to be provided, and instructed in the use of, a personal fall
arrest system which meets the requirements of Article 6, Appendix C, Section I of the
General Industry Safety Orders. The effect on the regulated public will be to clarify to
employers the fall protection requirements for window cleaners using boatswains
chairs or CDAs and to make these requirements consistent with the fall protection
requirements for employees using boatswains chairs or CDAs in other industries.

Section 3287. Ladders.

Subsection (a)(12) requires that no employee be allowed to stand on the top three rungs
of any ladder unless there are structural members that provide a firm handhold or the
worker is protected from falling by an approved safety belt or other equivalent means.
Proposed revisions will replace the outdated term "safety belt" with the term
"personal fall protection system", and add a new subsection (a)(12)(B)
restricting employees working on a stepladder from standing on the topcap or the step
below the topcap. The effect on the regulated public will be to clarify to employers the
fall protection requirements for window cleaners working from ladders and to make these
requirements consistent with the fall protection requirements found in the Construction
Safety Orders.

Subsection (c)(2) requires that personnel standing on unguarded roofs or ledges to
reposition davits be protected by an approved safety belt. Proposed revisions to this
section will require these employees to be protected by a personal fall restraint system
meeting the requirements of Section 1670 of the Construction Safety Orders. The effect on
the regulated public will be to require the employers to provide a personal fall restraint
system as described in Article 24 of the Construction Safety Orders.

Article 6. Powered Platforms and Equipment for Building Maintenance

Section 3293. Definitions.

This section states that the definitions for terms in Article 6 can be found in Article
5. The proposed amendment adds language stating that additional definitions may also be
found in Article 1, Section 3207. The effect on the regulated public will be to clarify to
the employer where definitions for the terms "Personal Fall Arrest System",
"Personal Fall Restraint System", "Personal Fall Protection System"
and "Positioning Device System" are located.

Article 6, Appendix C, Section I. Personal Fall Arrest Systems.

Section I of Appendix C sets out the criteria for personal fall arrest systems used by
all employees using powered platforms.

Subsection (b). Definitions.

Subsection (b) states that the definitions for terms in Article 6 can be found in
Article 5. The proposed amendment adds language stating that definitions may also be found
in Article 1, Section 3207. The effect on the regulated public will be to clarify to
employers where the terms "Personal Fall Arrest System", "Personal Fall
Restraint System", "Personal Fall Protection System" and "Positioning
Device System" are located.

Subsection (c)(10) requires that the anchorage for personal fall arrest systems be
capable of supporting at least 5400 pounds per employee attached. A revision is proposed
to reduce the anchorage requirement to 5000 pounds. The effect of the proposed action on
the regulated public will be to permit lower strength requirements for the fall protection
anchorage for employees using powered platforms for building maintenance to be the same as
those in other industries and consistent with the Federal OSHA standard.

Subsection (c)(11) requires that ropes and straps used in lanyards, safety lines, and
the strength components of body belts and body harnesses be made from synthetic fibers or
wire rope. A revision is proposed to remove the term "body belt" from this
requirement. The effect of the proposed action on the regulated public will prohibit body
belts from being used as part of a personal fall arrest system.

Proposed new subsection (c)(12) will require all body harnesses and lanyards
manufactured on or before January 1, 1998 to be designed and built to conform to ANSI
A10.14-1975, Requirements for Safety Belts, Harnesses, Lanyards, Lifelines and Drop Lines
for Construction and Industrial Use, which is incorporated by reference. There will be no
effect on the regulated public as body harnesses and lanyards are constructed to meet
these standards.

Proposed new subsection (c)(13) will require all personal fall arrest systems
manufactured after January 1, 1998 be designed and built to conform to either ANSI
A10.14-1991, American National Standard for Construction and Demolition Use, or ANSI
Z359.1-1992, American National Standard Safety Requirements for Personal Fall Arrest
Systems, Subsystems and Components, which are incorporated by reference. There will be no
effect on the regulated public as all personal fall arrest systems manufactured after this
date are already built to these standards.

Subsection (1)(A) requires that when stopping a fall, personal fall arrest systems
limit the maximum arresting force on an employee to 900 pounds when used with a body belt.
A revision is proposed to delete this subsection and renumber subsections (d)(1)(B)
through (d)(1)(D) accordingly. The effect on the regulated public will be to clarify to
employers that body belts shall not be used as part of a personal fall arrest system.

Subsection (e). Care and Use.

Subsection (e) contains mandatory care and use requirements for personal fall arrest
systems used by employees performing building maintenance from powered platforms.

The proposed amendment will insert a new subsection (e)(1) prohibiting the use of body
belts as part of a Personal Fall Arrest System, and to renumber subsections (e)(1) through
(e)(8) accordingly. The effect on the regulated public will be to clarify to employers
that body belts shall not be used for fall arrest.

Proposed new subsection (f)(2) will require that all personal fall arrest systems be
inspected at least twice annually by a competent person in accordance with the
manufacturers recommendations, and the date of the inspection be documented. The
effect on the regulated public will be that employers using personal fall arrest systems
for window cleaning and building maintenance will have to perform the same inspections as
employers using personal fall arrest systems in the construction industry.

Section II sets out test procedures that are used to determine compliance with
applicable requirements contained in Section I of this Appendix.

Subsection (b). General conditions for all tests in Section II.

Subsection (b) describes the general conditions to be used for all of the tests
described in this section.

Subsection (b)(1) states that during the required tests, safety lines, lanyards, and
deceleration devices shall be attached to an anchorage and connected to the body belt or
body harness in the same manner as they would be when used to protect employees. A
revision is proposed to delete the term "body belt". The effect on the regulated
public is to clarify to employers that body belts shall not be used for fall arrest.

Subsection (c). Strength Test.

Subsection (c) describes the tests to be used to determine that a fall arrest system
meets the strength requirementsoutlined in Section I of this Appendix.

Subsection (c)(3) requires that during the strength test for lanyard systems, thelanyards
be six feet in length measured from the fixed anchorage to the attachment on the body belt
or bodyharness. A revision is proposed to delete the term "body belt".
The effect on the regulated public will be to prohibit body belts from being used for fall
arrest.

Subsection (d). Force Test.

Subsection (d) describes the tests to be used to measure the maximum arresting force on
an employee using a fall arrest system as required by Section I of this Appendix.

Subsection (d)(2)(B) requires that during the force test, lanyards be six feet in
length measured from the fixed anchorage to the attachment on the body belt or bodyharness.
A revision is proposed to delete the term "body belt". The effect on the
regulated public will be to clarify to employers that body belts shall not be used for
fall arrest.

Subsection (d)(3)(B)(1) requires that the free fall distance, used in the force test
for deceleration systems that have a connection link or lanyard, be equal to the distance
between the centerline of the safety line and the attachment point to the body belt or
harness. A revision is proposed to delete the term "body belt". The effect on
the regulated public will be to clarify to employers that body belts shall not be used for
fall arrest.

Subsection (d)(3)(B)(4) states that a system fails the force test if the recorded
maximum arresting force exceeds 1,260 pounds when using a body belt, and/or exceeds 2,520
pounds when using a body harness. A revision is proposed to delete the force requirement
for a body belt. The effect on the regulated public will be to clarify to employers that
body belts shall not be used for fall arrest.

Section III provides non-mandatory guidelines which are intended to assist employers in
complying with the provisions of Sections I and II of this Appendix.

Subsection (c). Component Compatibility Considerations.

This subsection provides non-mandatory guidelines on the compatibility of fall arrest
devices, including body belts. A revision is proposed to delete the term "body
belt". The effect on the regulated public will be to clarify to employers that body
belts shall not be used for fall arrest.

Subsection (e). Instruction Considerations.

Subsection (e) provides non-mandatory guidelines on the types of instructions employers
should obtain from the supplier of the personal fall arrest system.

Subsection (e)(6) referencesthe proper hook-up, anchoring, and tie-off
techniques, including the proper dee-ring or other attachment point to use on the body
belt and harness for fall arrest. A revision is proposed to delete the term "body
belt". The effect on the regulated public will be to clarify to employers that body
belts shall not be used for fall arrest.

Subsection (j). Free Fall Considerations.

Subsection (j) provides non-mandatory guidelines on the effects of free fall distances
on users of personal fall arrest systems. A revision is proposed to delete the term
"body belt". The effect on the regulated public will be to clarify to employers
that body belts shall not be used for fall arrest.

Subsection (l). Obstruction Considerations.

Subsection (l) provides non-mandatory guidelines on the hazard of obstructions
in the potential fall path of an employee using a fall arrest system, including
obstructions that may interfere with the jack-knife motion an employee wearing a body belt
may experience. A revision is proposed to delete the language referring to the use of body
belts along with the jack-knife motion caused by the use of a body belt when arresting a
fall. The effect on the regulated public will be to clarify to employers that body belts
shall not be used for fall arrest.

These documents are too cumbersome or impractical to publish in Title 8. Therefore, it
is proposed to incorporate the documents by reference. Copies of these documents are
available for review during normal business hours at the Standards Board Office located at
1300 I Street, Suite 920, Sacramento, California.